Bureau Veritas: Helping Ship Owners Comply with Ballast Water Management Requirements

21/11/16

 

Ballast Water Management (BWM) Convention enters into force on September 8, 2017 and Bureau Veritas is on hand to support its clients in the countdown to compliance. To obtain their BWM Certification in time, BV advises that the process needs to be started now.


Alain Le Mith, Vice-President and Director of Operations for Bureau Veritas Marine and  Offshore, answers shipowners questions.


alain-le-mith-ballast-water-managementWhat do I need to do for my ship before September 8, 2017?

Le Mith: The Convention requires D-1 - Ballast Water Exchange - compliance immediately upon entry into force on September 8, 2017. Before this date, you will have to submit to Bureau Veritas a BWM Plan (compliant with the Guidelines for BWM and the development of BWM Plans - G4 - as set up by Resolution MEPC 127(53)) for review and approval.

Once approved by Bureau Veritas, you will have to place it on board together with a BWM Record Book. Once all this is ready, please call a BureauVeritas surveyor for survey and issuance of a BWM Certificate.

What if I already have a BWM Plan approved onboard?
Le Mith: An initial survey has to be performed for verification of the implemented method, based on which the BWM Certificate will be issued.

What will be required from ships which already have a BWM Plan approved and a Statement of Compliance issued?
Le Mith: An occasional survey, similar to the initial one, has to be performed for verification of the implemented method, based on which the BWM Certificate will be issued.

When will the D-2 standard apply to a ship?
Le Mith: Until now, the date a ship is required to comply with regulation D-2 – Installation of a Ballast Water System Management - is the date of the first renewal survey of the International Oil Pollution Prevention (IOPP) Certificate pursuant to MARPOL, Annex I, after the date of entry into force of the BWM Convention.

However, an alternate roadmap has been recently proposed, according to which key date for implementation of D-2 would not be the date of entry into force of the Convention but September 8, 2019. Thus, the renewal survey would be:

  • - The first renewal survey of IOPP certificate following the date of entry into force of the Convention if this survey is completed on or after September 8, 2019;

  • - The second renewal survey of IOPP certificate following the date of entry into force of the Convention if the first renewal survey following the date of entry into force of the Convention is completed prior to September 8, 2019.


When shall we know which the relevant renewal survey is?
Le Mith: These two different schedules will be discussed at the next Marine Protection Environment Committee of the IMO (MEPC 71) in May 2017 for possible final approval at MEPC 72 (May 2018). Uncertainty will remain at least until the MEPC 71.

How to cope with this unclarity?
Le Mith: Taking into account the first timescale, relying upon the date of entry into force of the BWM Convention, some ship owners have decided to anticipate the renewal survey.
Some Flag administrations have given case-by-case or in principle acceptance of de-harmonization between the IOPP renewal survey and the remaining renewal surveys.

How does this de-harmonization work in practice?
Le Mith: Two ways can be considered to renew the IOPP certificate:

  • - At the time of the annual survey, performing a renewal survey and to issue a new IOPP certificate;

  • - Outside the annual survey window, performing a renewal survey in order dedicated to the sole issuance of a new IOPP certificate.

The new IOPP certificate will be issued with a validity of five years from the date of survey.
The next renewal survey will be due five years later. So compliance with D-2 will also be compulsory five years later. Of course in the meantime, after September 8, 2017, the ship will need to operate in accordance with D-1 and hold a related BWM Certificate.

If I want to order a D-2 System, what are the compliance rules?
Le Mith: Ballast water has to be treated on board in order to fulfil the D-2 Standard that allows it to be discharged into the sea. For that purpose, there are different methods of treatment. Treatment systems should be type approved following the IMO guidelines (G8), and moreover, technologies that make use of active substances should be also approved by the MEPC of IMO (according to guidelines G9).

Are the Guidelines for approval of ballast water management systems (G8) supposed to evolve or to remain stable?

Le Mith: A first version of the guidelines G8 has been adopted on October 10, 2008 through resolution MEPC 174 (58). Revised guidelines have been adopted at the last MEPC. They will enter into force according to the following timeframe:

  • - Administrations apply the revised G8 when approving BWMS as soon as possible but no later than 28 October 2018;

  • - All BWMS installed on board ships prior to 28 October 2020 should be approved taking into account either resolution MEPC 174(58) guidelines or preferably revised guidelines (G8);

  • - BWMS installed on ships on or after October 28, 2020 should be approved taking into account the revised G8.
    Systems complying with the revised G8 guidelines will most likely be compliant with USCG Regulations (of course this will be subject to confirmation on a case by case basis with the USCG).

    And what about newbuiding ships?

    Le Mith: According to the timeframe that was prevalent so far, all ship constructed on or after the date of entry into force of the Convention (meaning 8 September 2017) shall comply with D-2 Standard.
    The alternate draft amendments that were put onto the table at next MEPC consider also a postponement of this implementation date to September 8, 2019.
    But as for the ships in service, decision might not intervene before MEPC71, even MEPC72.
    Therefore ship owners are invited to exercise a cautious approach.


    Bureau Veritas offers classification, certification and technical assistance. We approve technical documents such as the Ballast Water Management Plan, we perform ship survey and issue BWM Certificates.

    To learn more about the new International BWM Convention, download our complementary guide.
    To learn more about Bureau Veritas solutions, please visit www.bureauveritas.com/marine-and-offshore

Contact us

Bureau Veritas Marine & Offshore

Phone: +33 1 55 24 70 00

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